Tuesday, December 24, 2019

The American Civil War And Its Impact On American Society...

The modernizing of certain sports was a function of sociopolitical shift in the nation as a whole. Much of the transformation of American sport in the second half of the nineteenth century reflected the articulation and victory of free labor ideology in the American Civil War and its development into the commercial American society which would come to dominate American society. American sport reflected the white middle class values instilled by this ideology. Women continued to be discouraged from participation in physical recreation. In the former slave states, sport was used as a means for asserting white supremacy. The examination of sport in this period provides an example of how sporting culture is shaped by the sociopolitical climate in which it operates. Rising to prominence in the 1850s as the ideological foundation for the Republican Party, the doctrine of free labor celebrated the independent small businessman and farmer of the North. 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Johnson signed the Civil Rights Act of 1964, a law that ended discrimination in the US at all levels of government. Without the Civil Rights Act of 1964, blacks and other people of color would not have the opportunity

Monday, December 16, 2019

Porter Five Forces Assist an Organisation in Their Strategic Planning Free Essays

string(104) " a buyer and supplier relationship between the industry and companies which produces the raw materials\." How does Porters Five Forces Model assist an organisation in their strategic planning? Before understanding â€Å"how† we must know â€Å"what† Porters Five Forces model really is (Michael E. Porter, 2008). Company strive to secure a competitive advantage over their rivals, I mean who doesn’t want to be the best? Although the intensity of rivalry varies within each industry and these differences can be important in the development of strategy, but rather the five forces (Porter, 2008) being a strategy of any sort, it acts a framework in securing a strategy. We will write a custom essay sample on Porter Five Forces Assist an Organisation in Their Strategic Planning or any similar topic only for you Order Now The only time where strategy is irrelevant, would be when you have no competitors where ultimately the environment is a monopoly, or when you have a ton of money to throw around and waste. But having said that, it is not likely at all. Without framework, strategy will inevitably collapse, as they both come hand in hand. Thus a chain arises as the five forces (Porter, 2008) acts as a framework in assisting an organisation in their strategic planning, where strategic planning leads to a competitive advantage over their competitors which then leads to ultimate success of the company. Before proceeding to the question at hand on how Porters Five Forces can assist an organisation in their strategic planning, first we have to know two things, what are the Five Forces that Porter (2008) proposed, and ultimately what strategy really means? To ease this journey, let’s start with the Five Forces (Porter, 2008). Before any company enters a certain market, one must first analyse the competitive nature of the market, and this is exactly what the Five Forces (2008) aids to do, to provide a framework to determine the intensity of competition within an industry where three of the five competitive forces comes from an external sources, and the remainder coming from an internal sources. These external sources includes: Threat of potential entrants, threat of potential substitutes and rivalry of existing firms in the industry. Now these sources are external due to the fact that it is simply impossible to temper with. But what we can control, are the two internal sources: the bargaining power of suppliers, and the bargaining power of buyers. Being aware of the five forces can aid firms into identifying existence and the importance of each of the five forces, as well as the roles that each force plays into the success of the firms. The threat of potential entrants: Although it is possible for any company to enter and exit a market of their choice, each market has their own unique barriers to go in and out of. Therefore the essence of this force deals with the level of difficulty that a company can enter into an industry which will ultimately impact competition within the industry. Whenever a new company enters an industry, the competitive climate changes; it provides more alternatives to consumers, therefore reducing its attractiveness and the competition within the industry increases as each company is trying to come out on top. As each industry have their own unique characteristics it allows them to build a barrier from other industries protecting them from profitability while restraining additional rivals from entering the market. These restraints and characteristics that industries create are referred to as barriers of entry. Barriers of entry are a characteristic acquired uniquely to each industry. It attempts to reduce the rate of entry of new companies which maintains the level of profitability for all current industry competitors, where if new companies enters the industry, the profit is shared amongst the original and the newly developed companies in the industry, ultimately decreasing overall profits of each company, which isn’t ideal. Conversely when profitability of an industry is high, companies will attempt to come into the industry to get a piece of the action, which then will eventually result in reducing profits due to the fact that it is divided up into more quarters. Where there’s an entry, there’s an exit, barriers to exit limits the ability of a firm to leave the market, meanwhile rivalries can worsen. So when barriers for entry and exits are high, it means that companies have a higher potential to make more profit and the opposite occurs when barriers are low. The threat of substitutes: where it refers to substitute product as those that are available in other industry which can also fulfil the need and want of the consumers. It can affect competition in an industry by placing an invisible ceiling on prices which companies within the industry can charge, due to the fact that if the cost of substitute is low then the consumers will tend to purchase substitutes, therefore limiting the prices that a company can place on certain items to gain maximum profit. For example, lemonade can be substituted for a soft drink. Generally, competitive pressures arising from substitute products increase as the relative price of substitute products declines and as consumer’s switching costs decrease. The bargaining power of buyers is affected by the concentration and number of consumers, when buyer power is strong, they gain the power to choose between producers and ultimately equip themselves with bargaining power which then the producers will have to conform to in order to produce profit, under these conditions the buyer has the most influence in determining the price of products. Also when buyers have strong bargaining power in the exchange relationship, competition can be affected in several ways. Powerful buyers can bargain for lower prices, better product distribution, higher-quality products, as well as other factors that can create greater competition among companies. To minimise the power of buyers, companies can develop offers in which strong buyers cannot refuse, also, companies can choose to select buyers with less bargaining power. Similarly, the bargaining power of suppliers affects the intensity of competition in an industry, for a production industry that produces goods, raw materials are needed which creates a buyer and supplier relationship between the industry and companies which produces the raw materials. You read "Porter Five Forces Assist an Organisation in Their Strategic Planning" in category "Essay examples" Suppliers may be able to determine prices especially when there are a large number of suppliers, limited substitute raw materials, or increased switching costs. The bargaining power of suppliers is important to industry competition because suppliers can also affect the quality of exchange relationships. Competition may become more intense as powerful suppliers raise prices, reduce services, or reduce the quality of goods or services. In order to minimise the power of suppliers, industry tend to build win-win relationships with suppliers where both parties benefits from it or arrange to use multiple suppliers so if one supplier chooses to increase their prices, the company doesn’t get affected as much. Competition is also affected by the rivalry among existing firms, which is usually considered as the most powerful of the five competitive forces. In most industries, business organizations are mutually dependent, industries that are concentrated versus fragmented; often display the highest level of rivalry. A competitive move by one company in pursuing an advantage over its rivals can be expected to have a noticeable effect on its competitors, and thus, may cause retaliation of other companies, for example, lowering prices, enhancing quality, adding features, providing services, extending warranties, and increasing advertising, placing themselves in a competitive advantage over the competitors. The nature of competition is often affected by a variety of factors, such as the size and number of competitors, demand changes for the industry’s products, the specificity of assets within the industry, the presence of strong exit barriers, and the variety of competitors. These conditions will lead to a more challenging industry where companies compete in, leading to price wars, advertising battles, and the addition of new products. So after going through the five forces, let’s take a look at what strategic planning really means. If we are going to have a good strategy, we must separate strategy from goals and objectives and other issues that managers often think about. Now most management practitioners make the mistake in defining strategy, a strategy is what unique position that we will be able to achieve, what our advantage is going to be at the end of the day as we take these steps accumulatively over time, how we’re going to be unique? How we’re going to have an advantage? How we’re going to sustain the advantage over time? Schermerhorn, Davidson, Poole, Simon, Woods, Chau, 2011). The steps we take aren’t a strategy, but somehow numerous companies make the mistake of fixating themselves on a particular action that an organisation want to approach, which then inevitably becomes their strategy but that usually leads to the downfall of the company simply because they do not know why they’re doing it and when they should stop doing it. As we all know, every industry is diff erent, therefore, there is no universal strategy that can apply to any business. But before proceeding, a company must understand their position and the industry that they are in and their circumstances in order to find a way of obtaining a competitive advantage over the competitors, where indefinitely delivering a unique value to the consumers which rivals cannot. As the five forces (Porter, 2001) suggests that being at a competitive advantage is the idealistic way of being on top, due to the fact that every industry has their own set of economics, the five forces (Porter, 2001) without a doubt acts as a framework to extract any necessary information needed to develop strategy to gain competitive advantage. The Five forces (Porter, 2001) help you home in on what is really causing profitability, or in fact what is causing the trends of the significance and change of the industry. This powerful framework can prevent an organisation from getting tricked or trapped into the latest trends like the technological sensation, and really allowing organisations to focus solely on the underlying fundamentals. This can be applied to any industry whether if its production or a service, high tech or low tech, emerging or developed industries (Porter, 2001). With the framework at hand, it acts as a guide or even a tick off criteria sheet into strategic planning, how should we begin? The strategy formulating process will be pretty straight forward from here after deeply understanding the five forces which Porter (2001) proposed. The first step should be the analysis of the industry that a company is trying to get into, looking at the environment to tick off all of the 5 boxes one by one, evaluating what the industry looks like, how it’s been changing over time, and what are the drivers of competition (Schermerhorn et al, 2011). After a careful analyse the company is then required to under the dynamics as to where the industry is going, how the buyers and substitute’s entry level are evolving, and lastly how to position the company to gain a good profit. These are all extracted from the framework proposed by Porter (2001), although competition is sometimes looked at too narrowly, with careful analysis of the five forces (Porter, 2001) will ultimately position the company in a competitive advantage. Where a competitive advantage allows an organisation to deal with the market and environmental forces much better than its competitors (Ramon, 2012), to achieve this goal, the company needs to be at its best and better than the competitors who are trying to achieve the same goal in the same industry. Rather than a goal, competitive advantage is a position that a company wants to be in, a goal is to make the competitive advantage sustainable in spite of all the mockery of rivals, although achieving and sustaining it is a challenging task, but it will set concrete roots for the company in years to come. The implementation of strategic planning tools serves a variety of purposes in companies, including the clear definition of an organization’s purpose and mission, and the establishment of a standard base from which progress can be measured and future actions can be planned. I-O psychologist Ramon E, Henson (2012) and Robert E, Ployhart (2012) although having disagreements in some parts of their papers, they ultimately come forward in reinforcing the importance of competitive advantage suggesting that I-O and strategy has been â€Å"joined at hips for years† (Ramon, 2012), also suggesting hat I-O psychology should stray from the focus of individuals and start focusing more on the company as a whole as they have â€Å"much to offer† in the understanding of competitive advantage (Ployhart, 2012). Furthermore, the strategic planning tools should communicate those goals and objectives to the organisation as a whole rather than just the ones involved in the strategic p lanning process (O’Shannassy, 2003) to achieve a more efficient work flow. Throughout the centuries, countless strategic approaches has been formed and used and recycled, so why use Porter’s Five Forces (2008)? For example, strategy as simple rules Kathleen M. Eisenhardt, ; Donald N. Sull, (2001). It illustrates the success story of Yahoo! , along with other successful companies coming from an unattractive market. â€Å"So how they did succeed? More generally, what are the sources of competitive advantage in high-velocity markets? What does strategy mean in the new economy? † (Eisenhardt et al, 2001, p. 108). The key is none-other than strategy as simple rules, it targets market confusion and rides the magic carpet to see where or what it will journey into. Although it is indeed called â€Å"simple rules†, a rule still applies to it, as one Internet executive explained: â€Å"I have a thousand opportunities a day; strategy is deciding which 50 to do. † (Eisenhardt et al, 2001, p. 108). As it summarises and illustrates that simple rules is all about taking risks, its essence is to capture unanticipated opportunities for ultimate success. Although for companies like Yahoo! has gained huge success, simple rules (2001) cannot apply to any industry as the authors suggests (Eisenhardt et al, 2001). If the opportunity presents itself, for anyone to use simple rules (2001) as a stepping stone to success, without a doubt, one should take the opportunity, but an opportunity does not just come without any background knowledge of a particular industry, and this is where Porter’s Five Forces (2008) comes into play, as it provides a framework for careful analysis of the industry, by analysing the industry will allow you to grab hold of the opportunities that might come about. Despite the fact that there are numerous of strategies to obtain competitive advantage, Porters Five Forces (2008) acts as a basis of all these trategies, as it is a tick-off criteria sheet which allows a company to understand their position before even implementing any sort of action. It is important as companies strives for ultimate profitability, thus the importance of a company securing a competitive advantage over their competitors is key, as even I-O psychologists supports the important of competitive advantage and that it should be a â€Å"department on its own† (Ployhart, 2012). How to implement strategy and sustaining it is another question. Although Yahoo! nd some other companies has succeeded without the five forces (Porter, 2008), it is a dangerous and risky step, and for those who doesn’t have the resource to throw around, Porters Five Forces (2008) will not only act as a friend but mentor to the journey of success. Reference John R. Schermerhorn, Paul Davidson, David Poole, Alan Simon, Peter woods ; So Ling Chau (2011). Management 4th Asia-Pacific Edition. Queensland, Australia: John Wiley ; Sons Australia, Ltd. Kathleen M. Eisenhardt, ; Donald N. Sull, (2001). Strategy as Simple Rules. Harvard Business Review,79(1), 106-116. Porter E. Michael. THE FIVE COMPETITIVE FORCES THAT SHAPE STRATEGY. Harvard Business Review, 00178012, Jan2008, Vol. 86, Issue 1. RAMON M. HENSON. Industrial-Organizational and Strategy Are Integrated in Practice! Industrial and Organizational Psychology, 5(2012), pp82-86. Robert E. Ployhart. From Possible to Probable: The Psychology of Competitive Advantage. Industrial and Organizational Psychology, 5 (2012), 120–126. Tim O’Shannassy, (2003). Modern Strategic management: Balancing Strategic Thinking and Strategic Planning for Internal and External Stakeholders. Singapore Management Review, 25(1), 53-67. How to cite Porter Five Forces Assist an Organisation in Their Strategic Planning, Essay examples

Sunday, December 8, 2019

Taxation - Theory - Practice & Law Residence and Source

Question: Discuss about theTaxation, Theory, Practice Law for Residence and Source. Answer: Residence and Source The taxability of the income depends upon the residential status of a person, thus, it is crucial for the tax purposes to determine the residential status of a person (Prince, 2013). In Australia, the residential status of an individual is determined by referring to the provisions of Australian tax law and the rules framed by the Australian Taxation Office in this behalf. Although, there is a proper definition of the term Resident in the Australian tax laws but in certain complex situations, one may lead to refer to the judicial case laws. The judicial case laws also provide foundation to resolve the complex issues related to the taxation matters. However, it should be kept in mind that the judicial cases are referred to only in the situations in which the issues could not be resolved by referring to the statutory provisions of taxation law (TaxConnections, 2016). According to the rules framed by the Australian Tax Office, the primary test that is conducted to work out the residential status of an individual is the Resides Test. As per this test, an individual already residing in Australia is deemed as resident for the tax purpose without applying any other provision or rule. This implies that an individual residing permanently in Australia will always be deemed as resident for tax purposes. In case of individuals not already residing in Australia, there are three conditions stipulated by the Australian Tax office, if any of these conditions get satisfied, the individual is regarded as resident for tax purposes. These three conditions are discussed as under: Domicile Test: Prescribed that the individual having permanent place of residence in Australia is deemed as resident (Australia Residency Test, 2016). 183 Day Test: If an individual has stayed in Australia for a period of 183 days or more in the year for which status is sought to be determined, then he/she is deemed as resident of (Residency- 183 day test, 2016). Superannuation Test: As per this test, the Australian government employees posted outside Australia are treated as resident of Australia. However, in regard to the above discussed first two conditions, it is to be noted that if the Australian Tax Office is satisfied that the permanent place of abode of the individual is outside Australia, then these conditions will not apply and the individual may not be regarded as resident of Australia in that case (Australia Residency Test, 2016). In the present case, Fred, who has migrated to Australia from the United Kingdom, satisfies the 183 day test as he has been in Australia for 11 month (Australia Residency Test, 2016). Further, considering the prevailing circumstances in the current case, the permanent place of adobe for Fred could also not said to be outside Australia. This is primarily due to two reasons, first is that he is living in Australia with family (not considering children here because they could not be migrated due to unavoidable reasons) and second is that Fred has rented out his residential property of the United kingdom. Therefore, concluding the discussion, it could be articulated that Fred is resident of Australia for tax purposes and thus, he will be liable to pay taxes to the government on income earned there. Case study 2: Ordinary Income The outcomes in respect of the cases have been discussed as under: Case 1: Californian Copper Syndicate Ltd v Harris (Surveyor of Taxes) (1904) 5 TC 159 The primary issue arose before the court in this case was that whether a single transaction could be regarded as business and tax can be levied under the head business income on the person who carried out that transaction. Addressing this question, the first assertion of the court was that rather than thinking about the size of the transaction, one should consider the source from which that income emanates (Manyam, 2011). Thus, it becomes clear that for taxation purpose, even one single transaction could be brought to tax under the head business income, if the transaction was carried out with the business motive. Further, the court held that if the transaction related to land and property and securities was not with the business motive, rather the land, property or securities were held as investment, the gains can not be taxed as business income. The major outcomes of this case were as under: In case of land, property, and securities which are held as investment, the gains arising on sales or otherwise transfer of such land, property, and securities are not to be taxed as business income (MinterEllison, 2016). However, in cases wherein it is apparently clear that the activities are of business nature, the gains arising on sale or otherwise transfer of the securities, land, or property are to be taxed as business income (MinterEllison, 2016). Further, the court held that whether the transaction was a single transaction and whether or not it was commercial in nature, the gains arising from it shall be regarded as income, however, taxed it may be under any of the heads (MinterEllison, 2016). Further, the court stipulated that each case must be considered separately by going through the exact nature of the transaction (MinterEllison, 2016). Case 2: Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 Among various key cases on revenues and capital distinction for tax purposes, the Scottish Australian Mining Co Ltd v FC of T (1950) 81 CLR 188 is an important one (Smith, 2003). In this case, the major issue that came up before the court was that whether the sale of land, which was being previously used in the mining operations by Scottish Australian Mining Co Ltd, could be taxed as revenue income merely because that some business nature operations were performed by the company to bring that land in a saleable condition. Addressing this question, the court held that the income arising on sale of such land is not assessable income. The court based this decision on the assertion that business nature activities were taken up only to realize the land in the most advantageous way. Thus, in this case, the sale of land was held to be as not an assessable income (Smith, 2003). Case 3: FC of T v Whitfords Beach Pty Ltd (1982) 150 CLR This case involved a substantial question of law as regards taxation of sale of land. In this case, Whitfords Beach Pty Ltd purchased land in the year 1954, which was sold later on by carrying out some development work. Although, the primary issues in this case was same as that was raised in the case of Scottish Australian Mining Co Ltd but the circumstances were totally different. Court observed that the sale land in this case took place after altering the articles of association of the company so as to include wherein land development and sale as a business activity (Australian Government, 2016). Further, it was observed by the court that there was a change in the ownership that took place after the land was purchased. The court, by clearly making distinction between this case and the case of Scottish Australian Mining Co Ltd, held that the sale of land was assessable as business income. The judiciary observed that in this case, the taxpayer company was involved in more than the me re realization of the asset. Therefore, overriding the decision of the court in the case of Australian Mining Co Ltd, the court held that the sale of land by Whitfords Beach Pty Ltd was chargeable to tax as business income (Wolters Kluwer, 2016). Case 4: Statham Anor v FC of T 89 ATC 4070 In this case also the issue of tax on the sale of land was the reason of dispute between the taxpayer and the tax authorities. The taxpayer sold land, the net proceeds of which were assessed as the income from the business activities by the commissioner of income tax (Statham Anor. 2016). The taxpayer raised objections against the tax treatment given by the commissioner in respect of sale of such land. The taxpayer appealed in the court claiming that the tax treatment given by the commissioner is grossly wrong and the gains arising on the sale of land should not be taxed as business income. The court decided the case in favor of the taxpayer holding that the gains arising on the sale of land could not be regarded as the ordinary income or the income from business activities. The court based its decision on certain crucial grounds; one of them was that the activities of the taxpayer were not of business nature. In this regard, the court observed that the taxpayer was not working on any profit making scheme that could be associated with the sale of that land (Court Cases, 2016). Thus, in the prevailing circumstances, the taxpayer could not be held to be carrying on a business of land development. Further, the court ruled out that the mere fact that the farming business of the taxpayer was closed down, does not make the sale of land taxable as business income. Therefore, referring to the judicially pronouncements of other cases and considering the circumstances of the current case, the court held that the net proceeds of the sale of land can not be taxed as business income. Final order of the court also directed the commissioner to reimburse the expenses incurred by the taxpayer in connection with this appeal (Court Cases, 2016). Case 5: Casimaty v FC of T 97 ATC 5135 The law promulgated through this case was also to assist the taxation of the sale of land. In this case, the taxpayer was gifted a farm by his father. On this farm, the taxpayer was carrying on primary production activities and using a part of it for residential purposes. Later on, after several years, the taxpayer sold a part of the land from that farm (Casimaty's case, 2002). The tax authorities demanded tax on the gains arising on sale of that part of the land. The taxpayer challenged this decision of the tax authorities in the court by appealing that the gains on sale of part of the farm land were not chargeable to tax under section 25 (1) of the income tax assessment act (ITAA) 1936 (Australian Government, 2016). However, the decisions of the administrative appeal tribunal and the federal court came against the taxpayer. The federal court based its decision on the ground that the taxpayer was actively involved in planning and managing the sales of land, which in no case can be s aid to be involvement for mere realization of the asset. Challenging the decisions of the administrative appeal tribunal and the federal court, the taxpayer appealed in the high court. The high court turned down the decisions of the administrative appeal tribunal and the federal court by deciding the case in favor of the taxpayer. The high court held that the activities carried out by the taxpayer in connection with the sale of part of the land were not in the nature of business of land development (Casimaty's case, 2002). Thus, the gains arising from the sale of part of the land could not be taxed in the hands of the taxpayer under section 25 (1) of the ITAA 1936. The high court based its decision on the ground that the taxpayer was not directly involved in advertising the sale of land and other activities that are considered to be indicative of business of land development (Casimaty's case, 2002). Case 6: Moana Sand Pty Ltd v FC of T 88 ATC 4897 The sale of land and the dominant purpose of the taxpayer in selling that land was the primary finding of this case. The court observed that it is a well established law to consider the dominant purpose and intention of the party to use the land in deciding to tax the proceeds of sale of land. At the first stage, the tribunal asserted that the intention of the taxpayer was not to make profits from the sale of property. It was found that the taxpayer was using the land for the use in connection with the business activity such as sale of sand. Thus, the property was being used as the permanent asset in the business by the taxpayer and not as a trading asset. Based on these arguments, the tribunal held the gains on sale of land not chargeable to tax as ordinary business income (Moana Sand Case, 2016). However, on further appeal, the federal court pronounced that the sale of land in this case was chargeable on revenue account as well as capital account. Case 7: Crow v FC of T 88 ATC 4620 In this case, the court held that the activities of the taxpayer were identifiable in the nature of business of land development. Therefore, the court held the transaction of sale of land in this case was on revenues account and thus, liable to tax under section 25(1) of ITAA of 1936. The court observed that the description of the activities that the taxpayer was carrying in relation to the land development showed that these activities were in the nature of business (Crow v FC, 2016). In this regard, the court noted that the taxpayer carried out various land development tasks on such land before disposing that off finally. Further, in the case, the purpose behind purchase of the land was clearly identifiable, which was to carry out land development by subdividing it. Therefore, considering the stated purpose of use of land and the nature of the substantial activities that were being carried out by the taxpayer in relation to development of that land, the court pronounced that the sal e of land need to be brought to tax under section 25 (1) of ITAA 1936 (Crow v FC, 2016). Case 8: McCurry Anor v FC of T 98 ATC 4487 In this case, the court observed that the activities of the taxpayer in relation to land were not merely to assist in realization of the land, but these were more than that and signifying the existence of profit making motive. In this case, two brothers purchased a land and constructed three houses on that land. However, they were not able sale the houses initially and for that reason they decided to use two of the houses as residence. After some time using those houses for own residence, they sold them making huge profits out of that sale. The taxpayers were of the view that the profit earned on the sale of the houses was not chargeable to tax as ordinary income (Webb Martin, 2016). However, the court pronounced its decision based on the inherent intention of the taxpayer, which was to use the land in profit making activities and earn profit. The court based its decision on the finding that the taxpayer did not take required steps to let out the property and further, it was likely that to repay the heavy bank loan, they would be selling the property shortly (Webb Martin, 2016). References Australian Government. 2016. Income tax: whether profits on isolated transactions are income. [Online]. Available at: https://law.ato.gov.au/atolaw/view.htm?DocID=TXR/TR923/NAT/ATO/00001 [Accessed on: 10 August 2016]. Casimaty's case. 2002. Sale of subdivided farm land - Income or capital gain? [Online]. Available at: https://law.ato.gov.au/atolaw/view.htm?docid=AID/AID2002273/00001 [Accessed on: 10 August 2016]. Court Cases. 2016. Statham Anor v. Federal Commissioner of Taxation, Federal Court of Australia, Full Court, 23 December 1988 [Online]. 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